WASHINGTON, DC, UNITED STATES, May 20, 2026 /EINPresswire.com/ — A recently expanded Canadian citizenship law is raising unexpected questions for U.S. security clearance holders. On December 15, 2025, Canada’s Bill C-3, An Act to Amend the Citizenship Act, significantly broadened citizenship by descent, potentially extending Canadian citizenship to millions of individuals in the United States, many without any application or affirmative action.
While dual citizenship alone is not disqualifying for security clearance eligibility, national security attorneys warn that the change may create compliance and disclosure issues for cleared personnel under U.S. adjudicative guidelines.
“Dual citizenship is not in and of itself a security concern,” said Mathew Tully, Founding Partner at Tully Rinckey PLLC. “But how it is obtained, disclosed, and exercised can become highly relevant to eligibility determinations.”
Security clearance adjudications involving dual citizenship typically fall under Guideline C: Foreign Preference, which evaluates whether an individual may be inclined to act in the interests of another country over the United States in the event of a conflict.
Mr. Tully emphasized that assessments are fact-specific and consider both the country involved and the individual’s conduct. “In cases involving close allies like Canada, the baseline national security concern is low,” he said. “But adjudicators still focus heavily on the individual’s trustworthiness, reliability, and transparency.”
According to Mr. Tully, the most significant risk for clearance holders is not the existence of dual citizenship itself, but failure to properly report it under federal requirements, including SEAD-3 reporting obligations.
“Failure to disclose foreign citizenship or related activities can quickly escalate a Guideline C issue into a Guideline E personal conduct concern,” Mr. Tully said. “And in many cases, Guideline E is far more difficult to mitigate than the underlying issue.”
Guideline E applies when an individual is found to have knowingly withheld information, provided incomplete disclosures, or acted in a manner inconsistent with reporting obligations during the clearance process.
Mr. Tully notes that the expansion of Canadian citizenship under Bill C-3 includes individuals who may not have applied for citizenship or taken any affirmative steps to obtain it. This creates a unique situation for U.S. security clearance holders who may need to determine whether they now hold dual citizenship, and how to properly report that status.
“In some cases, individuals may not even know they have acquired foreign citizenship until they apply for formal confirmation,” Mr. Tully said. “That distinction matters when evaluating intent and compliance.”
Mr. Tully recommends that security clearance holders who may be affected take proactive compliance steps, including using a U.S. passport for international travel, reporting all foreign travel including to Canada, disclosing any change in citizenship status or related applications, and avoiding exercise of foreign citizenship rights where possible.
He stressed that adjudications are ultimately holistic in nature and often turn on credibility and candor. “It is unlikely that automatic Canadian citizenship alone would jeopardize a security clearance,” Mr. Tully said. “The greater risk arises when individuals fail to report changes or attempt to conceal them. In many cases, lack of candor is more damaging than the underlying facts.”
Individuals with questions about their specific clearance obligations are encouraged to consult a qualified national security attorney.
For more information on this new rule and how it impacts security clearance holders, please contact Scott Brewster at (202) 375-2251 or via email at sbrewster@tullylegal.com.
Scott Brewster
Tully Rinckey PLLC
sbrewster@tullylegal.com
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